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Since its introduction in 2001, the Indian transfer pricing regulations have gradually occupied the centre stage for tax litigation in India. Considering the drastic increase in the tax disputes involving transfer pricing cases, the last government had laid the stepping stone in resolving these disputes by introducing the Advance Pricing Agreement (APA) regime and the Safe Harbour rules. Keeping in line with the previous government, the newly formed NDA government has also brought in major reforms in TP regulations in the Union budget presented by the Finance Minister on 10th July 2014.
Astrazure’s one day workshop “Transfer Pricing - Evolving Landscape and Post Budget Implications” will throw light and insight on the current Transfer Pricing landscape in India with a comparative approach in purview of the existing Indian and prescribed global standards and guidelines highlighting the major changes in Transfer Pricing regulations in the Finance Bill 2014.
Benefits of attending:
- Practical Insights of the recent changes in TP regulations and it’s impact on organizations
- Evaluate and understand the changes in TP regulations in the Finance Bill 2014
- Hear from the best consultants/experts on various TP issues
- Understand the various documentary processes in relation to TP Audits
- Understand the requirements of a robust TP defense mechanism
- Understand the legal framework of Transfer pricing in India and various dispute resolution techniques
- Negotiation with APA Authorities
Who should attend:
- Tax Heads/ Tax Directors
- Direct Tax professionals
- TP Managers and Executives
- CFOs, COOs and Finance Directors
- Chartered Accountants
- Tax consultants and Practitioners
- Tax and TP Lawyers
Module I: Current Landscape of Transfer Pricing in India
- An overview of the Indian transfer pricing landscape
- TP litigation in India - key issues
- Indian TP laws vs OECD guidelines - need for further alignment?
- Base Erosion Profit Shifting (BEPS) - impact on Indian TP landscape
- Recent TP Developments in India (APAs, Safe Harbours, SDTs)
- Impact of New Companies Act/Clause 49 requirements on TP compliance
- Developing a long term TP compliance & dispute resolution strategy
1- Key announcements and implications of Finance Bill 2014
- Concept of inter quartile range – A big relief
- Use of multiple year data
- Roll Back Provision
- New Definition of a deemed international transaction
2- Companies Act 2013 – Impact analysis from RPT perspective
Module III: Advance Pricing Agreements
- Current Landscape and way forward
- Key features, benefits and challenges of India’s APA program
- When and Why to consider an APA in India
- How to design a winning APA Strategy
- Using APA as a tool for implementing transfer pricing planning options
- Negotiating with APA authorities
- Future of APAs in India
Module IV: Transfer Pricing Litigation
- Preparing for TP Litigation
- Current and emerging controversies
- Current status of transfer pricing issues pending before Tribunal/High Court
- Challenges and Key Leanings
- Advanced Ruling mechanisms
- Case Studies
1- Amitava Sen - Associate Director, Price Waterhouse & Co.
Amitava Sen is a Law Graduate and a Qualified Chartered Accountant. He has approximately 12 years of experience in all facets of Indian Transfer Pricing (TP) and has been involved in executing and managing TP assignments involving both inbound multinationals and outbound Indian groups. He has extensive experience dealing with Indian Revenue on TP matters at assessment and appellate stages. He has been on international secondments to PwC UK and PwC China where he has worked with the respective TP teams, thereby proving him global insights and experience on the subject.
2 - Aseem Chawla- Partner (Co-Founder), MPC Legal
Aseem Chawla is a Member of Bar Council of India & a Fellow Member of the Institute of Chartered Accountants of India, is (Founder) Partner and the Practice leader of the tax practice group at MPC Legal, New Delhi. He has been nominated as the Co-Chairman of the Direct Taxes Committee of PHD Chamber of Commerce and Industry, and as the Vice-Chair of the India Committee& Asia Pacific Committee of the American Bar Association Section of International Law (ABA). He has also been appointed to the Steering Group for the International Tax Committee of the American Bar Association.
3- Arun Chhabra - Director, Grant Thornton Advisory Pvt. Ltd.
Arun Chabbra is a Chartered Accountant and a Law Graduate. Arun has over 15 years of experience in dealing with various facets of Indian tax legislation relating to multinational and domestic companies including transfer pricing and tax litigation strategy. Arun focuses on matters relating to international tax, transfer pricing and tax dispute resolution and controversy management (including representing cases before tax authorities and tax tribunal). He regularly contributes articles in tax journals, tax conference booklets and is a speaker in tax conferences and seminars.
4- Partho Dasgupta - Partner Direct Tax, BDO India LLP
Partho Dasgupta is a Partner with BDO- Direct Tax practice. He has 20 years of professional experience, having spent 9 years in Deloitte in the Direct Tax domain. He was seconded to Tokyo for over a year to spearhead Direct Tax projects. He was also a part of BDO – Haribhakti, leading the Transfer Price practice. His functional expertise includes Accounting, Treasury, SAP implementation and Tax (including both taxes).He has successfully advised on and implemented various cross border structuring assignments, including devising the Transfer Price. He has worked with International networks & specializes in handling Japanese trading companies.